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Swap Dealers No-Action Relief DSIO

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
Latham & Watkins LLP

CFTC Issues No-Action Relief for Derivatives Market IBOR Transition

Latham & Watkins LLP on

While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more

Orrick - Finance 20/20

DSIO Issues Time-Limited, Conditional No-Action Relief for Excluding Certain Loan-Related Swaps from Counting toward the Swap...

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting...more

Katten Muchin Rosenman LLP

CFTC Extends Relief for Non-US Swap Dealers From Transaction-Level Requirements

On August 13, the Division of Swap Dealer and Intermediary Oversight, Division of Clearing and Risk, and Division of Market Oversight of the Commodity Futures Trading Commission extended no-action relief from certain...more

Katten Muchin Rosenman LLP

CFTC Issues Relief From IB and CTA Registration to Foreign Persons Dealing in Swaps for International Financial Institutions

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more

Katten Muchin Rosenman LLP

CFTC Extends CCO Report Filing Deadline

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued permanent no-action relief from the filing deadline for chief compliance officer (CCO) annual reports....more

Katten Muchin Rosenman LLP

CFTC Issues Relief to Swap Dealers Regarding Legacy SPV Swaps

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued no-action relief to swap dealers (SDs) from certain business conduct standards in dealing with...more

Orrick - Finance 20/20

CFTC Staff Issues No-Action Relief Regarding CCO Annual Report Timing Requirement

On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under...more

Orrick - Finance 20/20

CFTC Staff Issues No-Action Relief for Swaps with Legacy SPVs

On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when...more

Cadwalader, Wickersham & Taft LLP

CFTC Issues No-Action Relief for Amended Legacy Swaps between SDs and SPVs

On March 31, 2015, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”) issued no-action relief regarding compliance with certain of its swap...more

Katten Muchin Rosenman LLP

CFTC Issues Advisory on Ownership and Control Reporting

The Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission have issued an advisory on ownership and control reporting (OCR) for futures...more

Katten Muchin Rosenman LLP

CFTC Staff Extends No-Action Relief to Certain Reporting Counterparties Masking Identifying Information Pursuant to Non-US Law

On January 8, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) granted an extension of previously issued no-action relief for parties required to report identifying...more

Eversheds Sutherland (US) LLP

CFTC Grants No-Action Relief to Commodity Pool Operators with Respect to Certain Insurance-Linked Securitization Vehicles

Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued two letters affecting insurance-linked securitization vehicles: CFTC...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Relief Extending the Deadline for Certain CCO Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that extends the deadline for submitting the annual report that must be...more

Katten Muchin Rosenman LLP

CFTC Allows Swap Dealer’s CCO to Report to the Governing Body

On November 25, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter permitting the chief compliance officer (CCO) of a provisionally registered...more

Katten Muchin Rosenman LLP

Between Bridges: In Time for Christmas, CFTC Staff Gives FCMs, SDs and MSPs Gift of Time Extension to File CCO Annual Report;...

Just prior to Christmas 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight issued no-action relief extending the deadline by when chief compliance officer annual reports must...more

Katten Muchin Rosenman LLP

CFTC Extends No-Action Relief for Certain Transaction-Level Requirements for Non-US Swap Dealers

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01...more

Katten Muchin Rosenman LLP

CFTC Staff Extends No-Action Relief for Transaction-Level Requirements in Certain Cross-Border Situations

In an action parallel with the request for public comment (see “CFTC Requests Comment on Staff Advisory Regarding the Applicability of Transaction Level Requirements,” above), on January 3, the Commodity Futures Trading...more

Katten Muchin Rosenman LLP

CFTC Grants No-Action Relief to SDs and MSPs Regarding Relationship Documentation and Business Conduct

CFTC Grants No-Action Relief to SDs and MSPs Regarding Relationship Documentation and Business Conduct - The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued...more

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